Transition Finance Weekly - 11/13/2025

Unmarked Flood Zones; Large Load Rules; Small-Scale Solar; and Georgia PSC Race

Exploring the policy, politics, and economics of the clean energy transition

Each week here in Transition Finance Weekly, researchers and analysts from Pleiades Strategy summarize the top stories and trends related to the policy, politics, and economics of the clean energy transition in the states.

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BREAKING: We’re nerding out on this new paper from Climate Cabinet Education, released today, which highlights the economic regulatory policy and fiscal tools states have to address rising energy costs, skyrocketing household bills, and local clean energy financing gaps.

1. Large Load Rules Protect Consumers from Hidden Costs

Kansas and Michigan are tightening the rules for massive electricity users to make sure everyday customers aren’t left footing the bill.

• In Kansas, the Corporation Commission approved a settlement among Evergy, the Data Center Coalition, environmental groups, Google, and others, creating a “power service rate plan” for new facilities over 75 MW. The agreement includes a five-year ramp-up timeline, a 12-year minimum contract, minimum monthly payments, and transmission upgrades. Evergy has more than 20 potential large load customers totaling over 6 GW of demand, with roughly 15 GW in the pipeline across Kansas and Missouri, including 5 GW in advanced stages.

• Meanwhile in Michigan, Consumers Energy’s new rules for 100 MW+ loads set a 15-year minimum contract, require customers to pay 80% of expected monthly demand regardless of usage, and allow up to five years to reach full service levels. The state’s Public Service Commission requires the utility to ensure that costs from these large users aren’t subsidized by other customers.

• Looking ahead, Delaware legislators are considering S.B. 205, which would require the Public Service Commission to issue a “certificate to operate” for new loads over 30 MW. The bill would give regulators authority to require these users to secure their own generation and make financial commitments to cover transmission costs.

“On an annual power bill of $200 million, that extra 7-10% can significantly reduce costs that would otherwise be borne by the rest of Evergy’s customers,” the KCC said.

2. Pennsylvania Budget Passes, Climate Policy Sacrificed

After months of delay, the Pennsylvania legislature finally passed a budget — but in the process, lawmakers repealed Pennsylvania’s participation in the Regional Greenhouse Gas Initiative.

• Pennsylvania, where the state House has a Democratic majority and the state Senate is GOP-controlled, ended a four month budget impasse this week but with costly trade-offs for the state’s anti-pollution policy.

• In 2019, Gov. Tom Wolf directed the state to join RGGI, the regional carbon initiative that would have capped emissions from Pennsylvania companies and raised revenue that could support investments across the state.

• The policy, which was moving through a legal challenge, would have raised $1 billion annually to lower electricity bills and invest in local clean energy solutions.

• Environmental advocates have blasted the deal, brokered between legislative leaders and Governor Shapiro, for removing a key pathway for Pennsylvania’s clean energy leadership and consumers.

Manish Bapna, President and CEO of NRDC Action Fund: “With affordability fueling pro-clean energy candidate wins in elections across the country last week, this last-minute, head-scratching move feels very out of step with voters, and what Pennsylvania families actually need and want.”

3. Accurate Climate Data More Necessary Than Ever

Across the U.S., millions of homes are exposed to flooding but remain outside federally designated flood zones, leaving families unaware and underinsured.

• Banks, builders, landlords, and homeowners rely on federal maps to gauge flood risk — the costliest type of natural disaster in the country — but new reporting shows the maps fail to capture many at-risk properties, particularly in urban areas prone to heavy rainfall. Recent flooding in Milwaukee submerged hundreds of basements outside a federal flood zone, and much of the destructive flooding around Asheville, N.C., during Hurricane Helene last year was also in areas not mapped.

• The same issue emerged in Texas, where only 2% of homeowners along the Guadalupe River had flood insurance despite living in “Flash Flood Alley.” FEMA’s outdated maps did not classify most of the region as high-risk, leaving residents unprotected. Nationwide, a 2023 FEMA analysis found that 40% of flood insurance claims come from outside designated high-risk areas.

• The National Flood Insurance Program manages most U.S. residential flood policies, but mapping flood risk is a secondary function, and operations have not scaled to keep up with climate-driven changes. Data from First Street estimates that eight million properties fall inside FEMA-designated flood zones with a 1% or higher annual chance of flooding, while nearly 13 million properties outside those zones face the same level of risk.

The flood map “does not reflect all hazards,” said Andy Neal, who spent 15 years as the NFIP’s chief actuary before moving to insurance broker Aon in 2023. “The result is that there are a lot of people that have flood risk that don’t know about it.”

Source: Wall Street Journal and First Street Institute

4. Forced Coal Plant Closure Delays Threaten to Drive Up Costs for Rural Ratepayers

Colorado’s Craig power plant may be forced to stay open under new Trump Administration order.

• Despite years of planning to transition away from coal, Colorado’s Craig power plant may be forced to stay open if the Trump Administration moves forward with anticipated orders, an intervention that state leaders warn could raise energy costs and stall progress toward a cleaner, cheaper grid. Leaders at Tri-State G&T, the local utility that operates Craig 1, say they’re equally concerned about who will bear the financial burden.

• The administration made similar moves in Michigan and Pennsylvania, where it forced multiple utilities, who were retiring coal power plants, to keep them open longer. The administration reportedly also considered doing the same in Arizona with the Cholla coal plant, where the state’s entirely Republican-controlled Corporation Commission opposed the move.

• To do this, the administration invoked a little-used 1935 law to keep these coal plants online longer, over the objection of regulators, grid operators, utilities, and consumers — who have are on the hook for at least $80 million so far in Michigan and $70 million per year in Pennsylvania to keep these plants online.

“The Trump Administration wants to drag us backwards into an overreliance on a non-renewable resource creating a larger economic burden on the state and consumers,” said Jared Polis, Colorado’s Governor. “Orders like these would hurt Colorado ratepayers, and harm rural communities across the West who could be forced to absorb the unnecessary excess costs required to keep these unreliable plants operational.”

5. Another One Bites the [Coal] Dust

The Trump administration’s push to expand coal mining on public lands in Utah has hit a hard wall: no buyers.

• In early October, the administration opened thousands of acres for coal leases, including parcels near Zion, Bryce Canyon, and Capitol Reef national parks. The move followed the passage of the One Big Beautiful Bill Act and Trump’s executive order “Reinvigorating America’s Beautiful Clean Coal Industry.”

• The 48,000 acres on the auction block included multiple parcels east and north of Zion National Park, land bordering Grand Staircase-Escalante National Monument, and parcels directly adjacent to Capitol Reef National Park. Yet the auction drew just a single bid, which the federal government promptly rejected, echoing a similar outcome for coal leases in Montana.

• Across the country, 13 million acres of federal land recently opened for coal auctions are struggling to attract interest. The message is clear: the market has moved on, and coal is increasingly unwelcome, no matter how aggressively the administration pushes.

“Wind and solar, once they’re built, can produce electricity for nothing, practically,” said Joshua Linn, a professor at the University of Maryland who specializes in environmental economics. “Coal can’t compete with that.”

6. Oversight is the Adult in the Room

Wall Street sees consumer protection as a threat to the bottom line.

• Jefferies downgraded Southern Company from “Buy” to “Hold,” citing the arrival of two new PSC commissioners who ran their campaigns on holding Georgia Power to account for skyrocketing costs. Analysts estimate the change could slice roughly $12 billion off Southern Company’s valuation, lowering the price target from $114 to $103 per share. Unlike the prior commissioners, the newcomers are Georgia Power customers themselves and have promised tougher oversight over the utility.

• For years, observers criticized Georgia Power and the Public Service Commission for “irresponsible” investments in fossil fuel generation and large-scale capital projects, which are typically more profitable for vertically integrated utilities. Georgia Power is scheduled for a December 19 hearing, just two weeks before the new commissioners take office, on a request to add 10,000 MW of new generation. Clean energy and consumer advocates warn the plan risks locking in volatile gas costs.

“(It’s important) to have clear guardrails in place to make sure Georgia’s residential customers aren’t footing the bill for this massive expansion,” said Liz Coyle, executive director of the consumer advocacy nonprofit Georgia Watch.

SPOTLIGHT: Prices, Prices, Prices!

Wholesale electricity prices have surged as much as 267% in areas near major data center development, highlighting the hidden costs of rapid tech expansion. While data centers can help stabilize grids when properly integrated, these numbers show what happens when they simply draw massive amounts of power without thoughtful planning.

Also of note, there is new data from the Joint Economic Committee (JEC) that highlights which states are bucking the national trend of rising electricity costs. California, Nevada, and Hawaii stand out as the only states where rates have fallen. Everywhere else - surging prices, which are now driving the political conversation.